Ezel / IRS Rulings / 200908039

CCA 200908039: TEFRA issue required a partnership-level proceeding

Number
200908039
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Treatment Determined At Partnership Level
Topics
Procedure, penalties, and administration
Code sections
§ 6221
Ruling dated
November 18, 2008
Publicly released
February 20, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel answered a question about the TEFRA partnership procedures. The email concluded that the IRS would need to conduct a partnership-level proceeding in the case. The released text does not describe the facts, identify the particular partnership item, or provide further legal analysis. Its usefulness is therefore limited to the procedural conclusion stated.

Ruling snapshot

  • Question: Was a partnership-level proceeding required in the unspecified TEFRA matter?
  • Outcome: Advice given: yes, the matter required a partnership-level proceeding.
  • Key authorities: IRC § 6221.

Full text (IRS public release)

ID: CCA_2008111812090971 Number: 200908039
Release Date: 2/20/2009
Office: -------------
UILC: 6221.00-00

From: ----------------------
Sent: Tuesday, November 18, 2008 12:09:12 PM
To: ------------------
Cc:
Subject: RE: TEFRA Question

--------We would need to conduct a partnership-level proceeding in this case.

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